Viewing Grant Proposal: Slipstream Low Carbon Energy Planning

February 6, 2023 Michigan Public Service Commission PO Box 30221 Lansing, MI 48909 RE: Consumers Energy Swisslane Renewable Natural Gas proposal Consumers Energy Wilson Renewable Natural Gas proposal DTE Gas Benzie Manistee Wexford County Natural Gas Expansion proposal DTE Gas Delta County Natural Gas Expansion proposal DTE Gas Newaygo County Natural Gas Expansion proposal DTE Gas Oceana County Natural Gas Expansion proposal DTE Gas Osceola County Natural Gas Expansion proposal Dear Commissioners: As you know, the Michigan Propane Gas Association (MPGA) has expressed previous concerns about the potential projects that would be considered for the new Low Carbon Energy Infrastructure Enhancement and Development (EIED) Grants. The seven projects mentioned above, two from Consumers Energy and five from DTE Gas, justify the original MPGA concerns. While the two projects from Consumers Energy include the applaudable goal of renewable natural gas, both projects include natural gas line expansion to residential customers. All five of the DTE Gas proposals are blatant natural gas line expansion proposals. Natural gas utilities already have every ability to expand natural gas lines to the rural parts of Michigan. Neither Consumers Energy nor DTE Gas need to utilize taxpayer funds through the Low Carbon EIED grant program to expand natural gas as proposed in these seven projects. Both Consumers Energy and DTE report hundreds of millions of dollars in profits annually, and both utilities have more than enough resources to expand natural gas lines without taxpayer funded grants. Instead, the MPGA would argue that these grants should go to benefit local units of government with projects that benefit large communities. Additionally, this grant program does not require the utility companies to fix or upgrade their existing lines to protect their existing customers. Instead, natural gas leaks cause methane discharges, among the worst air pollutants and greenhouse gases. Both Consumers Energy and DTE Gas report that their estimated annual methane emissions to be tens of thousands of megatons each. In other words, if DTE Gas was to reduce its annual methane emissions by just 1 percent, then it would have a greater impact on global warming than the carbon reduction offered by all five of its above proposals combined. Additionally, if one were to prioritize reduction of carbon, then moving from propane to natural gas does not achieve that goal. The carbon intensity difference between propane and natural gas is negligible. In fact, according to a recent study conducted by GTI Energy for the Propane Education and Research Council (PERC) , the carbon intensity of propane consumed here in Michigan is 77.64 gCO2eq/MJ whereas the carbon intensity for compressed natural gas (CNG) is 78.21-80.59 gCO2eq/MJ. In essence, going from natural gas to propane can only be environmentally beneficial if the natural gas utilities eliminate the fugitive methane emissions from pipelines as the total carbon intensity between propane and natural gas is virtually identical. Of course, another factor not considered in the calculation of low carbon intensity is just how much carbon will be generated to dig up communities identified in these seven proposals to bury the new gas lines. By contrast, the propane infrastructure for customers is built to last for decades and is entirely recyclable including tanks, gas lines, valves, regulators, etc. at end of service life. Because propane systems are onsite energy systems (like solar or wind energy), there is no need to tear down trees, dig up right of ways to bury gas mains, nor otherwise harm the environment. Much like the claims for a lower carbon reduction are inflated, both Consumers Energy and DTE Gas inflate the cost savings by switching from natural gas to propane. Consumers Energy uses a basis of 1069 gallons for an average propane consumer and DTE uses 1050 gallons of propane use for its base calculation. For factual reference, the US Energy Information Administration (EIA) Residential Energy Consumption (REC) report lists an average residential usage in at 770 gallons per customer. The most recent calculations performed by Frost and Sullivan for PERC’s Annual Retail Propane Sales Report indicates that an average residential propane account in Michigan consumes 588 gallons per year. Even using the higher, more conservative amount of 770 gallons per year, Consumers Energy has inflated its calculations by 39 percent and DTE Gas has inflated its calculations by 36 percent. Both of those numbers greatly exaggerate any savings for consumers switching from propane to natural gas. Also exaggerated were the savings that homeowners will receive from the switch from propane to natural gas. Both Consumers Energy and DTE Gas acknowledge that homeowners will have upfront expenses to make the fuel switch to natural gas, and rebates of up to $500 will be provided. However, it is likely to cost homeowners thousands of dollars to buy or convert furnaces, water heaters, stoves, and/or clothes dryers. Additionally, those homeowners will have out-of-pocket expenses for customer attachment program (CAP) to make the fuel switch. As savings to homeowners is a priority of the Low Carbon EIED program, these projects seemingly miss that mark. Instead, the MPGA continues to encourage you to consider using this new grant program to focus on switching large industrial, agricultural and commercial operations that are currently using fuels such as coal, oil, or diesel to lower carbon intense fuels. Projects such as the Genesee County Digesters at Ragnone Wastewater Treatment Plant, the City of Lansing Wastewater Treatment Facility Solar PV and Aeration, the Kent County Bioenergy Facility, the Midland Cogeneration Venture Carbon Capture and Sequestration Feed Feasibility Study, and the Traverse City Solar and Battery Energy Storage at Wastewater Treatment Plant seemingly make better cases for lowering carbon intensity in our state. Projects like these will provide the greatest reduction in carbon and emissions while providing the greatest benefits to overall end-use customers. Respectfully submitted, Patrick Kolb

I support this project. The stated goal of the EIED grant program is to develop low carbon energy infrastructure, and the MI Healthy Climate Plan calls for Michigan to reach carbon neutrality by 2050, with a prioritization on actions that will provide the most rapid gains in GHG reductions. Additionally, many local governments and tribes here in Michigan have set even more ambitious goals that will help move our state to carbon neutrality in an equitable manner. But achieving these goals can be difficult for these local governments and tribes as they do not have the financial resources that are available to larger entities, such as large corporations that report profits in the hundreds of millions of dollars annually. Therefore, funds from this grant should go towards projects like this one. Through this project, multiple tribes, a historically and ongoing disenfranchised group, will be able to take advantage of low carbon energy planning resulting in deeper emission reductions in a more equitable manner than some of the other proposals that only offer marginal emission reductions at best.

I am strongly in support of this proposal. Both state and local governments have set ambitious goals for carbon neutrality, but achieving these goals can be difficult for many local governments due to a lack of financial resources – whereas large corporations that report profits of hundreds of millions of dollars should already have the funding for this work. Therefore, I strongly believe that funds from this grant program, the goal of which is to develop low carbon energy infrastructure, should go towards projects like this one. This project would allow multiple tribal entities statewide to take advantage of the resources that are developed to support their own plans for low carbon infrastructure. This will lead to deeper and more equitable emissions reductions than will many of the other proposals up for comment.

Slipstream is a trusted and valuable actor in the equitable energy space, and what better use of these dollars than helping Native Nations access clean energy. Strong support.

We support this project and its tie to energy equity. Too often tribal governments are left out of conversations about decarbonization or are second thoughts in our efforts. Having a funded projects that helps these sovereign nations plan for a decarbonized future that is responsive to their cultural, social, economic, and community priorities is key. As such, we support this project and the foundation it will lay for future energy work on tribal lands.

I am in support of this project. Many Nations have ambitious GHG reduction goals that are focused on equity, but it can be difficult for many of them to achieve their GHG reduction goals since they do not have the same financial resources as large corporations. With the implementation of this project, Nations could take advantage of the resources that are created to push forward low-carbon infrastructure in an equitable way, and achieve greater admissions reductions than several other proposals that offer much more marginal emissions reductions and may put us on the wrong path. This project also aligns well with the stated goal of the EIED grant program to develop low-carbon infrastructure. Therefore, this project should be strongly considered for EIED grant funds.

I strongly support this project. Entities like Native Communities don't have the same financial resources as large corporations, so proposals like this one should be prioritized. Implementing renewable energy solutions is necessary to reducing our greenhouse gas emissions, and is directly inline with the stated EIED goals. This should be strongly considered for funding.